ORDER OF THE GENERAL COURT (Second Chamber)
3 November 2014 (*)
(Procedure — Taxation of costs — Representation of an institution by a lawyer — Recoverable costs)
In Case T‑381/06 DEP,
FRA.BO SpA, established in Bordolano (Italy), represented by F. Distefano, lawyer,
applicant,
v
European Commission, represented by V. Bottka and H. Leupold, acting as Agents,
defendant,
APPLICATION for taxation of costs lodged by the Commission pursuant to the judgment of the General Court of 24 March 2011 in FRA.BO v Commission (T‑381/06, EU:T:2011:111),
THE GENERAL COURT (Second Chamber),
composed of M.E. Martins Ribeiro (Rapporteur), President, S. Gervasoni and L. Madise, Judges,
Registrar: E. Coulon,
makes the following
Order
Facts and procedure
1 By Decision C(2006) 4180 of 20 September 2006 relating to a proceeding under Article 81 [EC] and Article 53 of the EEA Agreement (Case COMP/F‑1/38.121 — Fittings) (summary published in OJ 2007 L 283, p. 63; ‘the Fittings Decision’), the Commission of the European Communities found that a number of undertakings had infringed Article 81(1) EC and Article 53 of the Agreement on the European Economic Area (EEA) by participating, over various periods between 31 December 1988 and 1 April 2004, in a single, complex and continuous infringement of the Community competition rules taking the form of a complex of anti-competitive agreements and concerted practices in the market for copper and copper alloy fittings, which covered the territory of the EEA. The infringement consisted in fixing prices, agreeing on price lists, agreeing on discounts and rebates, agreeing on implementation mechanisms for introducing price increases, allocating national markets, allocating customers and exchanging other commercial information and also in participating in regular meetings and in maintaining other contacts intended to facilitate the infringement. (judgment of 24 March 2011 in FRA.BO v Commission, T‑381/06, EU:T:2011:111, paragraph 1).
2 FRA.BO SpA (‘FRA.BO’), a producer of copper fittings, is among the addressees of the Fittings Decision.
3 By application lodged with the Registry of the Court on 15 December 2006, FRA.BO brought an action seeking the partial annulment of that decision in so far as it imposed on it a fine of EUR 1.58 million and, in the alternative, a reduction in the amount of that fine reflecting the value of its cooperation.
4 That application forms part of a series of 10 actions for annulment of the Fittings Decision (Viega v Commission, T‑375/06; Legris Industries v Commission, T‑376/06; Comap v Commission, T‑377/06; IMI and Others v Commission, T‑378/06; Kaimer and Others v Commission, T‑379/06; FRA.BO v Commission, T‑381/06; Tomkins v Commission, T‑382/06; IBP and International Building Products France v Commission, T‑384/06; Aalberts Industries and Others v Commission, T‑385/06; and Pegler v Commission, T‑386/06). Moreover, an application for interim measures was lodged in IBP and International Building Products France v Commission (T‑384/06 R), which also concerned the Fittings Decision.
5 By judgment in the case FRA.BO v Commission, cited in paragraph 1 above (EU:T:2011:111), the Court dismissed FRA.BO’s action and ordered it to pay the costs.
6 On 10 February 2012, the Commission sent a debit note to FRA.BO for an amount of EUR 17 260, comprising EUR 17 000 representing the lump sum of the fees paid to the Commission’s lawyers and EUR 260 for the administrative costs of the Commission’s agent, indicating 26 March 2012 as the final date for payment. Since FRA.BO had not made any payment by that date, the Commission sent it a letter of reminder on 8 May 2012 and a letter of formal notice on 14 June 2012, demanding payment of the initial sum together with interest for late payment.
7 By letter of 18 July 2012, FRA.BO disputed the fact that the lawyers’ fees and the corresponding interest could be regarded as recoverable costs. In particular, it maintained that the assistance provided by the Commission’s lawyers was not necessary and that the decision to appoint lawyers in the FRA.BO v Commission case, but not in certain parallel cases, was unfair and discriminatory.
8 By letter of 19 July 2012, the Commission responded that it was not in a position to reconsider the claim of EUR 17 260 and interest accrued.
9 On 11 February 2013, in an e-mail sent to the Commission, [confidential]: (1)
[confidential]
10 By letter of 3 July 2013, FRA.BO informed the Commission that it maintained its concerns regarding the Commission’s request for recovery of legal costs and requested the Commission to provide it with information that would enable it to verify the extent and value of the work carried out by the Commission’s lawyers, in particular the contract and the lawyers’ note of fee listing the number of hours worked and the hourly rate applied.
11 By letter of 18 July 2013, the Commission again responded that it was not in a position to reconsider the claim of EUR 17 260 and interest accrued. By that letter, the Commission also sent the contract and lawyers’ note of fee to FRA.BO. It is apparent from paragraph 2 of that contract that the Commission had committed to paying its lawyers the fixed sum of EUR 17 000 to cover the entirety of their fees, expenses, charges and costs, and that that overall amount of remuneration was broken down into distinct payments corresponding to the various stages of the proceedings (50% after the lodging of the defence, 25% after the lodging of the rejoinder and 25% after the hearing).
12 By letter of 5 August 2013, FRA.BO, while confirming that it maintained its concerns regarding the claim for recovery of costs in respect of lawyers’ fees, proposed to the Commission to pay the sum of EUR 7 033 in order to settle the matter out of court. [confidential]
13 By e-mail of 6 August 2013, the Commission rejected that offer of settlement and stated that it would go to court for taxation.
14 By e-mail of 12 August 2013, FRA.BO proposed to the Commission to begin discussions with a view to reaching a settlement out of court.
15 By document lodged at the Court Registry on 4 December 2013, the Commission submitted an application for taxation of costs by which it requested that the Court fix the amount of recoverable costs to be reimbursed by FRA.BO.
16 By document lodged at the Court Registry on 18 March 2014, FRA.BO submitted observations on that application.
Forms of order sought
17 The Commission claims that the Court should:
– fix the amount of the Commission’s costs relating to the proceedings in case T‑381/06, which have to be reimbursed by FRA.BO, at the sum of EUR 18 576, representing EUR 17 000 in lawyers’ fees, EUR 260 in administrative costs of the Commission’s agent and EUR 1 316 in interest for late payment until the day of the application for taxation;
– award further interest in the amount of EUR 2.13 for each additional day of delay (representing an annual interest rate of 4.5%), and
– include the costs of the Commission relating the present proceedings for taxation of costs in the event of a hearing.
18 FRA.BO contends that the Court should:
– fix the amount of the costs incurred by the Commission in the proceedings in Case T‑381/06 at EUR 260 (for the administration costs of the Commission’s agent) and reject the Commission’s claim for the sum of EUR 17 000 in lawyers’ fees;
– in the alternative, fix the amount of costs at a level the Court deems to be ‘indispensable’ for the purpose of the proceedings in Case T‑381/06 and, at the very least, reduce by 25% the sum of EUR 17 000 claimed by way of lawyers’ fees (namely EUR 4 250, corresponding to the amount charged for the hearing);
– reject the Commission’s claim for interest.
Law
19 Under Article 92(1) of the Rules of Procedure of the General Court, if there is a dispute concerning the costs to be recovered, the General Court hearing the case is, on application by the party concerned and after hearing the opposite party, to make an order, from which no appeal shall lie.
20 According to Article 91(b) of the Rules of Procedure, ‘expenses necessarily incurred by the parties for the purpose of the proceedings, in particular the travel and subsistence expenses and the remuneration of agents, advisers or lawyers’ are regarded as recoverable costs.
21 It follows from that provision that the recoverable costs are limited, first, to those incurred for the purpose of the proceedings before the Court and, secondly, to those which were essential for that purpose (orders of 28 Juin 2004 in Airtours v Commission, T‑342/99 DEP, ECR, EU:T:2004:192, paragraph 13; of 10 February 2009 in Centeno Mediavilla and Others v Commission, T‑58/05 DEP, EU:T:2009:31, paragraph 27; and of 27 November 2012 in Gualtieri v Commission, T‑413/06 P‑DEP, EU:T:2012:624, paragraph 18).
22 Moreover, in the absence of EU law provisions laying down fee-scales, the Court must make an unfettered assessment of the facts of the case, taking into account the purpose and nature of the proceedings, their significance from the point of view of Union law as well as the difficulties presented by the case, the amount of work generated by the proceedings for the agents and advisers involved and the financial interests which the parties had in the proceedings (see, to that effect, orders of 10 September 2009 in C.A.S. v Commission, C‑204/07 P‑DEP, EU:C:2009:526, paragraph 14; of 20 May 2010 in Tetra Laval v Commission, C‑12/03 P‑DEP and C‑13/03 P‑DEP, EU:C:2010:280, paragraph 44; Airtours v Commission, cited in paragraph 21 above, EU:T:2004:192, paragraph 18; and Centeno Mediavilla and Others v Commission, cited in paragraph 21 above, EU:T:2009:31, paragraph 28).
23 In fixing the recoverable costs, the Court takes account of all the circumstances of the case up to the making of the order on taxation of costs, including the expenses necessarily incurred in relation to the taxation of costs proceedings (orders of 23 March 2012 in Kerstens v Commission, T‑498/09 P‑DEP, EU:T:2012:147, paragraph 15, and of 28 May 2013 in Marcuccio v Commission, T‑278/07 P‑DEP, ECR, EU:T:2013:269, paragraph 13). Unlike Article 87 of the Rules of Procedure, which provides that a decision as to costs is to be given in the final judgment or in the order which closes the proceedings, Article 92 of those Rules does not contain such a provision (see, by analogy, orders of 28 February 2013 in Commission v Marcuccio, C‑513/08 P‑DEP, EU:C:2013:109, paragraph 22, and Commission v Marcuccio, C‑528/08 P‑DEP, EU:C:2013:110, paragraph 32; order of 16 May 2014 in Marcuccio v Commission, T‑491/11 P‑DEP, EU:T:2014:513, paragraph 9).
The lawyers’ fees
The recoverability of the lawyers’ fees incurred by the Commission
24 It is clear from the first paragraph of Article 19 of the Statute of the Court of Justice, applicable before the General Court pursuant to the first paragraph of Article 53 of that Statute, that the institutions of the Union are free to have recourse to the assistance of a lawyer. Remuneration of the latter therefore comes within the concept of expenses necessarily incurred for the purpose of the proceedings (see, to that effect, orders of 16 May 2013 in Internationaler Hilfsfonds v Commission, C‑208/11 P‑DEP, EU:C:2013:304, paragraph 14, and of 10 October 2013 in OCVV v Schräder, C‑38/09 P‑DEP, EU:C:2013:679, paragraph 20; order in Kerstens v Commission, cited in paragraph 23 above, EU:T:2012:147, paragraph 20), without the institution being required to show that such assistance was objectively warranted (see, to that effect, orders of 31 January 2012 in Commission v Kallianos, C‑323/06 P‑DEP, EU:C:2012:49, paragraphs 10 and 11, and Marcuccio v Commission, cited in paragraph 23 above, EU:T:2013:269, paragraph 14). Therefore, the Court has already held that whilst the fact that the Commission instructed two agents and an external lawyer has no impact on the possible recoverability of those costs, since there is nothing to preclude such recovery in principle, it may have an impact on the determination of the amount of costs incurred for the purposes of the proceedings which may ultimately be recovered (orders in Kerstens v Commission, cited in paragraph 23 above, EU:T:2012:147, paragraph 21, and Marcuccio v Commission, cited in paragraph 23 above, EU:T:2013:269, paragraph 14). There is thus no question of an infringement of the principle of equal treatment between applicants in the event that the defending institution decides to have recourse to the services of a lawyer in certain cases, whereas in others it is represented by its agents (orders in Marcuccio v Commission, cited in paragraph 23 above, EU:T:2013:269, paragraph 14, and of 16 September 2013 in Marcuccio v Commission, T‑9/09 P‑DEP, EU:T:2013:506, paragraph 29).
25 Any other assessment which makes the right of an institution to claim all or part of the fees paid to a lawyer subject to proof of an ‘objective’ need to use that lawyer’s services would in fact constitute an indirect restriction on the freedom conferred by the first paragraph of Article 19 of the Statute of the Court of Justice and entail for the European Union judicature a duty to substitute its own assessment for that of the institutions and bodies responsible for the organisation of their departments. Such a task is compatible neither with the first paragraph of Article 19 of the Statute of the Court of Justice, nor with the power to adopt rules for their own internal organisation enjoyed by the institutions and bodies of the European Union in relation to the management of their cases before the courts of the European Union. On the other hand, whether account should be taken of the involvement of one or more agents alongside the lawyer in question is a matter for the discretion vested in the Union judicature in proceedings for the taxation of costs under Article 91(b) of the Rules of Procedure (see paragraphs 20 to 22 above) (orders in Marcuccio v Commission, cited in paragraph 23 above, EU:T:2013:269, paragraph 15, and Marcuccio v Commission, cited in paragraph 24 above, EU:T:2013:506, paragraph 30).
26 With regard to the action concerning the Fittings Decision, for eight of those cases, the Commission concluded contracts with external lawyers, while the other two cases were handled by two Commission agents without external assistance. In particular, in four of the English-language cases (T‑378/06, T‑381/06, T‑382/06, T‑386/06), including the case brought by FRA.BO, the Commission was assisted by the same law firm.
27 In the present case, the Commission claimed by way of lawyers’ fees an amount of EUR 17 000 corresponding to the lump sum paid to its lawyers.
28 FRA.BO argues that those fees were not necessary for the purpose of the proceedings. It maintains that, in the context of parallel actions brought by competing companies against the same Commission competition decision, the Commission has a specific duty to ensure that the fundamental principle of equal treatment is respected when it allocates cases to external lawyers, just as it should be ensured when fines are imposed on companies. In FRA.BO’s view, the fact that larger competitors brought actions in cases that were clearly more complex, and either did not have to bear any of those costs, or had to pay as much as FRA.BO, constitutes discrimination.
29 In that regard, it should be recalled, as is apparent from the case-law cited in paragraph 24 above, that there can be no question of an infringement of the principle of equal treatment between applicants in the event that an institution decides to have recourse to the services of an external lawyer in certain cases, while in others it is represented by its agents.
30 In so far as FRA.BO disputes the relevance of the case-law cited in paragraph 24 above, on the ground that, in Marcuccio v Commission (EU:T:2013:506, cited in paragraph 24 above), the applicant had raised the principle of equal treatment in relation to an overly broad category, including all applicants in civil service cases, while arguing the need to ensure equal treatment between participants in an infringement under Article 101 TFEU, it must be held that that argument cannot succeed. That FRA.BO’s action is one of a series of parallel cases involving the same Commission competition decision does not warrant departing from the case-law cited in paragraph 24 above. The financial burden arising from the obligation to pay the costs of the lawyers’ fees incurred by the Commission does not form part of the fine imposed for an infringement of competition rules, but is a consequence, first, of the fact that the Commission exercised its right to use the services of an external lawyer, which applies irrespective of the nature of the case, and, secondly, of the dismissal of the action for the partial annulment of the decision imposing the fine, leading to costs being awarded against FRA.BO.
31 Accordingly, it must be held that the lawyers’ fees incurred by the Commission are recoverable costs.
The amount of the recoverable lawyers’ fees
32 It should be borne in mind at the outset that the European Union judicature is authorised not to tax the fees payable by the parties to their own lawyers, but to determine the amount up to which that remuneration may be recovered from the party ordered to pay the costs (see, to that effect, orders of 10 September 2009 in C.A.S. v Commission, C‑204/07 P‑DEP, EU:C:2009/526, paragraph 13; of 13 February 2008 in Verizon Business Global v Commission, T‑310/00 DEP, EU:T:2008:32, paragraph 29; and of 31 March 2011 in Tetra Laval v Commission, T‑5/02 DEP and T‑80/02 DEP, EU:T:2011:129, paragraph 55 and the case-law cited). In the same vein, the fixed nature of the remuneration has no effect on the Court’s assessment of the amount recoverable by way of costs, since it bases its decisions on well-established criteria laid down by case-law and precise information which the parties must provide to it (order in Marcuccio v Commission, cited in paragraph 23 above, EU:T:2013:269, paragraph 20).
33 In order to determine, on the basis of the criteria set out in paragraph 22 above, whether the costs actually incurred for the purposes of the proceedings were necessary, precise information must be supplied by the applicant (see, to that effect, order of 9 November 1995 in Ahlström, C‑89/95 DEP, EU:C:1995:366, paragraph 20). Whilst the absence of such information does not prevent the Court from fixing, on the basis of an equitable assessment, the amount of recoverable costs, it none the less places it in a situation where its assessment of the applicant’s claims must necessarily be strict (see orders in Gualtieri v Commission, cited in paragraph 21 above, EU:T:2012:624, paragraph 54, and Marcuccio v Commission, cited in paragraph 23 above, ECR, EU:T:2013:269, paragraph 16 and the case-law cited).
34 In the present case, with regard, in the first place, to the purpose and nature of the proceedings, their significance from the point of view of EU law as well as the difficulties presented by the case, it should be recalled that the action brought by FRA.BO, which was one of 10 parallel actions for annulment involving cartels, sought both the partial annulment of the Fittings Decision in so far as it imposed on FRA.BO a fine of EUR 1.58 million as well as a reduction in the amount of that fine. In support of the action, FRA.BO relied on two pleas in law, alleging, first, an improper application of the Commission notice on immunity from fines and reduction of fines in cartel cases (OJ 2002 C 45, p. 3) and, secondly, an improper application of the principles of the Commission Notice on the non-imposition or reduction of fines in cartel cases (OJ 1996 C 207, p. 4) (judgment in FRA.BO v Commission, cited in paragraph 1 above, EU:T:2011:111, paragraph 26). In those circumstances, the Court’s judgment provided some clarification regarding the concept and application of the ‘partial immunity rule’. While the case as a whole does not appear to be of particularly great significance from the point of view of EU law, it must be considered that the questions the proceedings raised in relation to cartels did present an appreciable degree of difficulty and complexity.
35 In the second place, with regard to the financial interest the parties had in the proceedings, it must be noted that the amount of the fine, namely EUR 1.58 million, was not very high in comparison to the other fines imposed by the Fittings Decision. In addition, FRA.BO emphasises that its action sought only a reduction in the amount of that fine. The Commission had granted it a 20% reduction in the EUR 1.97 million amount for leniency, whereas FRA.BO took the view that a reduction of 50% would have been appropriate taking into account the value of its contribution to the Commission’s investigation. In such a situation, FRA.BO considers that the economic interest at stake corresponded to 30% of EUR 1.97 million, namely EUR 591 000. Nevertheless, that sum represented a considerable financial burden for FRA.BO, having regard in particular to the size of the company. The Commission, for its part, maintained that it defended its decisions irrespective of the amount of the fines imposed.
36 In the third place, as regards the amount of work the proceedings generated for the Commission’s lawyers, it should be recalled that the Commission claims an amount of EUR 17 000 which corresponds to a lump sum negotiated with those lawyers in order to cover the entirety of their fees, expenses, charges and costs, and that that overall amount was broken down into separate payments corresponding to the various stages of the proceedings. Specifically, 50% of the remuneration was charged after the lodging of the defence, 25% after the lodging of the rejoinder and 25% after the hearing.
37 In the present case, the Commission’s lawyers provided services during the written phase and the oral phase of the proceedings.
38 In that regard, the Commission observes that the tasks carried out by the lawyers included discussing the case with the Legal Service and the Directorate-General team in charge of the case, studying the file, preparing drafts of the defence and rejoinder, and preparing for and attending the hearing with the Commission’s agent.
39 Moreover, it must be stated that the Commission has not submitted a detailed statement of the services provided by the lawyers, nor does it specify the number of hours of work they needed for carrying out each of their services.
40 With regard to the oral procedure, it is common ground that it was the Commission’s agent that pleaded during the hearing and not the lawyers who were also present. By contrast, during the hearing in the parallel case IMI and Others v Commission (T‑378/06), concerning the same cartel and taking place on the same day, a lawyer of the Commission pleaded.
41 In so far as FRA.BO infers from that fact that, in the present case, the lawyers’ assistance was not objectively necessary and that, in the alternative, it would be appropriate to reduce the costs claimed by the Commission by at least 25% (namely EUR 4 250), corresponding to the remuneration linked to the hearing, so as to reflect the lower volume of work provided in the FRA.BO case in comparison to the parallel proceedings, for which the lawyers received the same fixed sum, its argument cannot succeed.
42 First, it is not appropriate to assess the value of the lawyers’ work by comparison to the services they provided in the parallel proceedings, but rather to determine the extent to which the costs incurred for the services the lawyers provided in the present case are recoverable. Secondly, even if the lawyers did not plead during the hearing, the fact remains that they did provide services during the oral procedure.
43 In that context, the Commission states that its lawyers assisted it in the preparation for the hearing, including on the draft oral pleading and on the report for the hearing, and that they assisted the pleading agent with research and input for responding to the Court’s questions.
44 Having regard to the factors set out above, the amount claimed by the Commission by way of lawyers’ fees, namely EUR 17 000, may be regarded as necessary within the meaning of Article 91(b) of the Rules of Procedure. Even though the Commission has not specified the number of hours of work carried out by its lawyers, which would have been preferable, its information on the breakdown of the amounts of the fees according to the various stages of the proceedings and the services provided by the lawyers during the written procedure and the oral procedure make it possible in this case, particularly in the light of the purpose of the proceedings and the difficulties of the case, for the Court, while taking into account all the circumstances of the case, to conclude that the amount claimed does not exceed the costs which are recoverable. In view of all the foregoing considerations, the costs recoverable by way of lawyers’ fees can be assessed on an equitable basis at EUR 17 000.
The disbursements
45 In respect of disbursements of its agent, the Commission is entitled to claim the reimbursement of EUR 260, an amount undisputed by FRA.BO, so that the total amount of the recoverable costs comes to EUR 17 260.
The Commission’s claim regarding default interest
46 The Commission claims that the Court should fix costs corresponding to EUR 1 316 in interest on late payment until the day of the application for taxation and interest in the amount of EUR 2.13 for each additional day of delay.
47 In that regard, it must be stated that the finding of any obligation to pay default interest and the fixing of the applicable rate fall within the exclusive competence of the Court under Article 92(1) of the Rules of Procedure (see, by analogy, order of 29 September 1995 in ENU v Commission, C‑2/94 SA, ECR, EU:C:1995:301, paragraph 10; order of 25 March 2014 in Marcuccio v Commission, T‑126/11 P‑DEP, EU:T:2014:171, paragraph 51).
48 However, according to settled case-law, an obligation to pay default interest can arise only where the amount of the principal sum owed is certain or can at least be ascertained on the basis of established objective factors (see, to that effect, judgment of 1 June 1994 in Commission v Brazzelli Lualdi and Others, C‑136/92 P, ECR, EU:C:1994:211, paragraph 53 and the case-law cited; order in Marcuccio v Commission, cited in paragraph 23 above, EU:T:2014:513, paragraph 31). The right of the Commission to reimbursement of costs has its legal basis in the order fixing them (see, to that effect, order of 18 April 1975 in Europemballage and Continental Can v Commission, 6/72-DEPE, ECR, EU:C:1975:50, paragraph 5). Consequently, a claim for an award of default interest calculated from a date prior to the date on which the order that fixed the costs was made must be dismissed (see, to that effect, order of 6 January 2004 in Mulder and Others v Council and Commission, C‑104/89 DEP, ECR, EU:C:2004:1, paragraph 86; order of 24 October 2011 in Marcuccio v Commission, T‑176/04 DEP II, EU:T:2011:616, paragraph 36).
49 By contrast, the Commission’s claim must be upheld in so far as it seeks the fixing of default interest for the period between the date of the service of this order and the date of the actual reimbursement of the costs (see, to that effect, order of 3 May 2011 in Comtec Translations v Commission, T‑239/08 DEP, EU:T:2011:191, paragraph 39; order in Marcuccio v Commission, cited in paragraph 48 above, EU:T:2011:616, paragraph 36).
50 With regard to the rate of interest applicable, the Court considers it appropriate to take into account of Article 83(2)(b) of Commission Delegated Regulation (EU) No 1268/2012 of 29 October 2012 on the rules of application of Regulation (EU, Euratom) No 966/2012 of the European Parliament and of the Council on the financial rules applicable to the general budget of the Union (OJ 2012 L 362, p. 1). Consequently, the rate applicable is to be calculated on the basis of the rate applied by the ECB to its principal refinancing operations and in force on the first calendar day of the month in which the due date falls, increased by three and a half percentage points (order of 16 January 2014 in Marcuccio v Commission, T‑450/10 P‑DEP, EU:T:2014:32, paragraph 47).
On those grounds,
THE GENERAL COURT (Second Chamber)
hereby orders:
1. The total amount of the costs to be reimbursed by FRA.BO SpA to the European Commission is fixed at EUR 17 260.
2. That sum is to bear interest for late payment from the date of the service of this order until the date of payment.
Luxembourg, 3 November 2014.
E. Coulon | | M.E. Martins Ribeiro |